Discovery powers apply to unauthorised payment charges

The taxpayer was a member of a self-invested personal pension plan (SIPP). In October 2006 the SIPP made a loan to a third party B the terms of which stated that it had to be repaid within a year and was to be used to buy development property. B loaned the money to the taxpayer. 

In July 2009 the taxpayer told his SIPP provider to transfer his fund to another pension provider which then made a loan to another third party D. It was agreed that this was for a three-year term and the funds were to be used for investment purposes. D then loaned the funds to the taxpayer. The loan to D was repaid in 2013 but the loan to B has not been repaid.

In 2017 HMRC issued discovery assessments for 2006-07 and 2009-10 for the unauthorised payments charge...